Week of September 25

CRE has conducted an in-depth review of the kratom issue and has read and benefited from the numerous comments posted on this website. Based on the said information, CRE has developed a proposal for addressing the issue.

We welcome public comments prior to arriving at a final position. Please note that the CRE position is contingent on the DEA not taking any additional action on its intent to ban kratom.

Comments can be posted at the bottom of this page. To this end see the insightful comments of Ms. Susan Ash filed at 2:02 PM September 28 below regarding actions by the DEA.

9/28 Regulation of kratom as a dietary supplement.

The following from the comments CRE received:

George

September 23, 2016 at 3:02 pm

Thank you CRE for continuing to follow this. Regulation as a dietary supplement is the correct thing for the United States to do.

I too had heard the rumor that a large treatment center was behind the ban in one state. I look forward to reading what you uncover.

CRE

September 27, 2016 at 10:26 pm

We would be interested to determine how many in the kratom community share your insight as to having kratom regulated as a dietary supplement

9/27 Public Contact with the DEA

CRE received the following email from a reader; CRE has had a completely different experience when we contacted DEA. They were professional and helpful.

Good evening,

I tried calling the DEA to please stop the ban on the wonderful herb Kratom. What I got was rudeness and they actually were laughing. They are unprofessional and they don’t care about the people. Many people will suffer and may die without Kratom. They laugh and think it’s funny. This is the same response they are giving with many people that are calling as well. Please. Please help stop the ban on Kratom. It would be a grave mistake to take it away from so many people.

. . .The ideal analgesic would not have the high risk of addiction, withdrawal or fatal respiratory slowdowns that have turned opioid abuse into a massive epidemic. The holy grail of painkillers would not induce the seductive euphoria of common opioids or their less-pleasant side effects like itching or constipation.

A painkiller with just one of these properties would be great, but Majumdar thinks he has stumbled onto a class of chemicals that might have them all. They are found in kratom, a plant that the U.S. Drug Enforcement Administration intends to effectively ban from the U.S. in an emergency move as early as September 30. Without legal access to it, research on some of the most promising leads for a better painkiller may grind to a crawl.

9/25 Bipartisan Support Against A Ban

In divided DC we seldom see both parties agree on anything. In this instancewe note that influential members of Congress in both parties have opposed the kratom ban.

9/24 An Immediate Solution

The DEA states in its Federal Register Notice:

Additionally, this action is not a significant regulatory action as defined by Executive Order 12866 (Regulatory Planning and Review), section 3(f), and, accordingly, this action has not been reviewed by the Office of Management and Budget (OMB).

In its letter to the DEA, with a copy to OMB, CRE recommended that the “final order” be submitted to OMB because in fact it is a “significant regulatory action” because it changes the legal rights and obligations of a large number of Americans. (Ask any 1L law student who has taken administrative law.)

The immediate solution is to demand that DEA send the final order to OMB for review prior to publishing it in the federal register–in the alternative OMB can simply deem the kratom order to be a “significant regulatory action”–game over (at least for a while).

9/24 An Interesting Observation in Forbes Magazine

The following is from Forbes Magazine.

Note to readers: I’ve been reminded that the September 30 date may not necessarily be the effective date. Instead, it’s the earliest that DEA can issue its final order. As written under ‘Supplementary Information’ in the Notice of Intent in the Federal Register: “Any final order will be published in the Federal Register and may not be effective prior to September 30, 2016.” Therefore, sale and possession of kratom products may still be permitted after this date. I will update this post when the final order is published.

9/24 To The Citizens Of Canada

We appreciate your continued efforts to encourage your government officials to educate their counterparts in the United States of the dire consequences of a US ban of katrom.

9/24 To a Reddit Author : Get A Life!

We note this post on Reddit made in response to a CRE post on this website.

Is this legit? Hard to trust something with such an obvious typo: “opiod”

CRE is a nationally recognized regulatory watchdog that has defended kratom with little financial support from the community and at a negative visibility cost to us and our traditional work. Defending kratom is hardly a popular cause.

Lack of financial support makes it difficult to assign staff for peer review to an account which is a financial loss. Check out our credentials. We welcome your calling attention to our typos but those of you who believe that counting the number of typos is a justifiable metric to assess to our legitimacy have a far greater problem then the DEA.

Fortunately the outpouring of support for CRE’s work dwarfs the views of a vocal minority, but it is time for some internal policing by the community in terms of how they address both the supporters and opponents of kratom.

Ad hominem attacks against established institutions, be they CRE or DEA, diminishes ones credibility. This website is one such forum for conducting the aforementioned self policing; CRE looks forward to seeing the results of such policing.

Week of September 18

9/23 Worth a read; See this comment CRE received

Kratom Research Institute September 23, 2016 at 12:59 am

Canada currently regulates kratom as a legal Natural Health Product. Canada has seen no deaths or public health problems associated with having kratom legally available as a dietary supplement. Regulating kratom as a legal dietary supplement is the correct approach for the United States.

9/23Incarceration

CRE is receiving reports that in some states that have kratom bans individuals are being incarcerated; CRE also has received, but has not confirmed, that in one of the aforementioned states that a very large chain of opioid treatment centers was behind the ban.

yes that state got kratom banned because it was affecting their bottom line. The public is not stupid. People are able to connect the dots. Slowly we are changing the views that just because the news states something is true doesn’t mean it is true. As we have seen there are news people who don’t use facts or any evidence to back up their often incorrect information.

I live in Arkansas where kratom was banned without legislation last February. They posted a public hearing date, however the doors were closed that day and kratom was already banned 3 days earlier. The top prescribing methadone/suboxone Dr (Thomas Atkinson) with a financial investment in the rehab centers of Northwest AR suggested that kratom be banned to the Director of the Dept of Health. The director banned it with a pen stroke and it wasn’t until April that anyone even knew. I personally know several people who now go to that Dr for methadone. I know others who have relapsed and turned to illegal drugs. People who were safely and effectively quitting opiates with kratom alone. This was a gross bureaucratic grab that shows a clear, financially motivated conflict of interest. I pray this nationwide ban is stopped so we don’t see a huge rise in opiate abuse, overdose and imprisonment of responsible citizens who rely on kratom to relieve their ailments.

This Dr. Atkinson peddles Methadone and Suboxone and has a drug treatment facility in Fayetteville, Arkansas. He notified the Health Department and just like that it was banned. The comment period was 30 days and nobody knew about it. A coroner stated Kratom was linked to 3 deaths around the same time. It is kind of like what happened federally with the DEA now. Do you think the DEA decided to sneak it through , following Arkansas example?? So tired of corruption.

It is pointless to throw hardworking, tax paying Americans under the bus and into the prison system over trying to treat their pain and improve their lives with kratom. It is the most counterproductive and counter-intuitive piece of drug legislation I have ever seen. There has to be an ulterior motive behind this.

Neither of these facts surprise me! Kratom is safe, and Canada recognizes that, just like the US DEA needs to. The fact that for-profit dug rehabilitation centers were behind the outlawing of kratom in a couple of states is also very believable; these facilities that like the public to believe they are in the business of “helping people” care about nothing but profits. They want people to keep taking and relapsing on deadly opiates so they can continue to earn profits off their stays at the facilities.

I’m sure opioid treatment centers were behind it. How else are they gonna get everybody to stay on Suboxone & methadone? Those drugs are horrifically difficult to get off of, & cause many other issues, but they’re raking in big bucks getting people on them. The DEA should act like decent, human adults, say ok maybe we were wrong here, & stop this mess. But we all know they aren’t decent people. Big money’s being passed around to try to ban kratom, cuz without it people can’t get away from the super expensive prescribed maintenance meds. It’s sickening.

Scary thing that all of the statistics are coming from the CDC. They are also padding the numbers on deaths from prescription opioids. They count anyone that dies with opioids in their system regardless of the cause of death and they don’t separate deaths from heroin or other opioids from prescription overdose deaths. In other words if a 747 goes down and everyone has opioids in their system they are counted and if you shoot up heroin and croak you are also counted as a prescription opioid death. The CDC director Tom Frieden and his good buddy Andrew Kolodny, the founder of PROP and Phoenix House Rehab Centers director, go back a long way. They both worked at the NYC Health department and they were on a crusade then to get everyone on Suboxone. Recently the CDC came out with their guidelines for prescribing opioids without any input from pain specialists or pain patients. They also tried to post these guidelines without any comment period from the public but were called out on it by The Washington Legal Foundation. Only then did they allow the “required 30 day comment period” but had already made up their minds and wrote the guidelines with no significant changes. One of the advisers for the CDC was Dr. Jane Ballantyne. She is now the president of PROP (Physicians for Responsible Opioid Prescribing). She had been a paid advisor by a law firm that would sue the pharmaceutical companies for getting everyone hooked on opioids. One case in California the judge put the lawsuit on the back burner because the regulating agencies really didn’t have guidelines at the time and how can he be the judge of how many opioids were too much without guidelines. Then suddenly we had guidelines from the CDC which are so ridiculous right down to suggesting that all patients be drug tested. Think about that one. If your grandma has chronic pain issues she has to be drug tested in order to get relief from her pain. Shaken down like a criminal for the crime of being in pain. Now the CDC released the statistics claiming that kratom deaths have had a significant increase in the past 5 years. Notice they had to use 5 years’ worth of data to keep from being laughed at.
There is a lot of garbage and manipulating coming out of the CDC and it appears to be driven by the addiction industry. There is a lot of garbage and manipulating coming out of various agencies surrounding addiction. Something is very wrong here and these agencies are finding Kratom a big threat to their bottom line.!

Cre please forgive any of the nit pickers. Some folks will gripe if you give them a million dollars. I want to thank for standing up for what it right. You people have a love of justice and that is worth everything. Thank you from the bottom of my heart for your help. Praying for you to get everything you need to continue your work. This site has gotten me interested in issues facing this country. God Bless you all Cre and continue to fight the good fight.

If special interests benefit from the suffering of those affected by this ban it is an outrage. A light needs to shine on the forces that have pushed this hasty attempt to ban kratom. I hope that records are requested and released from the DEA and FDA, through open records request or litigation, that will allow the public to see why this was supplement was deemed an imminent threat to the public. Thousands of responsible Americans benefit from kratom for various health reasons, who does this ban benefit? Can federal agency functionaries negatively impact the lives of so many Americans based on bad data and false conclusions, as well as create a dangerous black market, at the snap of a finger? Thank you, CRE

Thank you CRE for continuing to investigate this matter in the interest of justice. Many people who rely on kratom for quality of life despite chronic pain are incredibly grateful such a credible watchdog organization has gotten involved. What is happening is wrong on so many levels, and it takes a talented team with knowledge and resources to investigate and expose this fully. Many of us have been distracted from our ordinary lives in the past few weeks, crippled with fear, and facing an uncertain future regarding our health and ability to manage various conditions without our safe, natural, and effective approach with kratom. Please keep digging and giving a voice to people who are hurting from this injustice.

Thanks CRE for fighting for the kratom community! This whole ban issue is unacceptable. The DEA is discrediting itself with their lack of research /regard for public opinion. Mr. Rosenberg has no business policing kratom especially when his background is big pharma. This whole emergency ban reeks of corruption

My concern is that no matter how big the groundswell of opposition has been to the DEA’s criminalization of kratom, the ban is more or less occurring as we speak. They are moving ahead with this unilaterally, without any seeming concern for who may want more information, or may question the secrecy or haste surrounding this move.

Reports are surfacing of vendor raids, product seizures, even arrests — a full week before the EARLIEST permitted launch of the ban. On the financial side, I have heard many reports that credit card processors are now denying transactions for kratom-related products. I heard from one vendor first-hand that he was forced to start using a foreign credit card processor, at much higher expense to his business and much higher risk to his customers, because his longtime processor suddenly dropped his account. He is currently fighting for funds they are holding from him, for no apparent reason than he is a kratom vendor.
The damage has been done.
So perhaos the ban cannot take effect until Sept. 30. Perhaps it may not even take effect then. Perhaps we may win a delay in the ban. But does any of this really matter when the DEA has created such hysteria that the damage is already done? I want to know if vendors whose livelihoods have been destroyed — as well as consumers whose lives have been destroyed — by this ban have any recourse in civil court.
I am also interested in knowing if this ban, and all of the suffering it will cause, has any Constitututional implications. I would think that when you cause undue harm and pain — possibly death — to a citizen of the United States through a decision you cannot even defend with evidence, you may bear some liability. But I am not a lawyer.

I would imagine a move like this will cause such a backlash to the Agency that they might be dissolved as a result of the damage they have already caused in at least two different countries. This was calculated perfectly according to their plan.

“Significant regulatory action” indeed it is. This proposed ruling, if enacted, will completely kill my business and leave me and contractors jobless (and their families will hurt financially and emotionally). In addition, I will be unable to pay future tax obligations. I won’t be able to get back to generating income as a result of my own medical conditions which led me to discovering life-saving help from this tree. Basically, my life will be the way it was before I found it, miserable, only this time, I have much more financial obligations (rent, car payment, college loans, kids to feed, disabled wife). This ridiculous proposed ruling came out of nowhere, with no warning. 30 days is not enough time to make changes, and we were expanding. Not only is this causing me future losses, we have to ditch all other projects/investments made in June through August. We were beginning a huge project that almost put us in a hole, and now this…

Sorry IRS… Although I became a better taxpayer and made you enormous revenue, now another department in our Government has decided to cut your tax revenue off. State Comptroller, I collected so much sales tax revenue for you, but the government is cutting that off too. You’ll understand though, as you fly the USA flag higher than yours. USPS, all the extra revenue we’ve been paying for your already unstable service is going away thanks to a Government agency – hopefully you can find it in your heart to not layoff the loyal Postal workers I wave to each day. All the other couriers we support, you’ve been great. Amazon, I won’t be spending much money at your marketplace as I have been. It is amazing to imagine the effect I’ve had on the economy. My own customers… it makes me sad to think about them. I have thousands of customers who relied on me, many I considered as family. It hurts me most to think about how many of them (also their families and contractors/employees) will have a sudden change of life. The whole world is affected by this event. There were so many people involved here in the USA but also tens of thousands in other countries already directly affected by this. The economy will take a noticeable hit.

Vendor: This is a compelling story, and it would be very easy for you and thousands of kratom vendors to demonstrate harm. I wonder if you would have any recourse in the courts. A class-action suit representing thousands of vendors across the U.S., for whom the DEA has made an irrevocable business decision (i.e., to put you OUT of business) without due diligence and based on drummed-up statistics.

…it’s if the plan was so carefully sculpted. The coverage on elections, economy, and the usual distractions that occur during elections (like police on citizen crime, gun control) are ramped up as expected. There may not be an economy left to sue over.

I believe the media coverage about opioid deaths will be something to focus on after the ruling takes place (if it does). It is unknown whether or not the CDC will actually report success in deaths numbers decreasing, but we know the reality is that the numbers will rise. It is important for everyone to realize that the reason we would see a rise in deaths is because this herb is being made Schedule I. Inversely, a reduction in deaths would be due to the public attention this month has brought our industry in the case that the ban be delayed or halted.

I have great concern that this ban will actually contribute to overdose deaths. Seems of such small concern when so many are losing their lives to heroin and prescription overdoses. We can’t put the opiate genie back in the bottle. But kratom can help.
Seven died in a SINGLE Ohio county last weekend from laced heroin. Now, the DEA seeks to take action against Kratom? This is an extremely poor use of resources. Hopefully, the DEA will be able to get the quality of heroin back to normal. Too many have died.

Hi CRE, I just wanted to comment on the Redditor who was rude to you because of a typo. I think that is horrible of them, and like you wisely pointed out, being so unnecessarily critical reflects poorly on the person being critical, and not on the object of their criticism. On behalf of that mean and rude person I would like to personally thank you for all the time you’ve spent helping the kratom community. As you point out, kratom is not a popular cause, and you are helping us without being paid to do so. I really sincerely appreciate every post you’ve made, every thing you have written, the fact that you created a virtual docket that the public can participate in, and all the amazing research that you did to figure out which laws the DEA broke by going about scheduling kratom in the way they did. You have helped us so much, and I am ashamed of people who treat you poorly when we should all be THANKING you and APPRECIATING you instead. Shame on that Redditor and all others who don’t know a good thing (you) when they see it.

We appreciate your support. We assume the author of the Redditor comment is a supporter of kratom whose heart is in the right place and probably just had a bad day. We probably wrote the response when we had a bad day also.

We also appreciate your highlighting the virtual docket which is the conveyor belt that takes all the informative comments we received from persons like you and transports them into the federal regulatory process.

Thank you CRE for your continued support in this matter. I am disturbed by the grammatical comment as well, and I hope know that we are very grateful for all of the work and research you have put into this. I am sorry that they were so careless with their words. I hope we win this fight, however, I hear that the DEA is now just hanging up on anyone calling and mentioning the word Kratom. I guess this is all a joke to them. It is a shame that so many elderly will be effected as well as veterans who have served our country well. Please don’t give up on us! We desperately need your help. Thank you!

We do not believe DEA is taking kratom as joke because if they were they would not be listening to the comments of the kratom community by their continuing visits to this website. We also believe they are overwhelmed with the comments they are receiving. Hopefully they will realize that kratom is the solution, not the problem.

The DEA did not hang up on me. I have called twice. they did accept my opinion to not schedule Kratom, but to treat it as an herbal supplement instead. When I started providing them with my reasons, they said that they were not interested to hear my story… but that they would acknowledge my comment. I asked then if with all of the pushback if they still planned to schedule Kratom, and he said “Yes, absolutely as a schedule I. We can’t say when, but it will be scheduled. “

Regarding the 9/28 entry regarding kratom being sold as a dietary supplement, I do not agree with that direction. For over a decade. Many reputable vendors have successfully sold this material with no structure/function claims under the botanical specimen name. This disqualifies it as a dietary supplement. For vendors who do this, the customer database is always extremely loyal, and there are rarely any instances where customers have unrealistic expectations. Such customers have done all of their own research before purchase, and the vendor makes no claims. The material is basically just sold as a botanical specimen, that’s it. The vendor also does not sell encapsulated product that implies consumption. Harm is reduced when the seller does not make claims nor markets in a way that attracts drug users, a win-win for all. The current method by reputable vendors attracts only knowledgeable adults. Marketing is never suggestive like Camel cigarettes, alcohol, or other dangerous substances. To bring regulation into an already self-regulated market will be a step in the wrong direction.

The problems are with retail novelty stores (headshops, smokeshops) – it is these guys who had no conscience selling “bath salts” just before they found a plant to fill a void (when “bath salts” became illegal). Headshops are known by everyone as the place to locally buy whippets, “legal highs”, synthetic drugs, and sex toys. They need to be regulated, not the kratom industry.

The rule should be that sellers may not make any structure/function claims, and the natural leaf material should be sold only by its botanical name, not the slang “kratom” word. Leave that word to the headshops who want to cater only to those who can better pronounce “kra-tom” versus “Mitragyna speciosa”. The way sellers control the industry trends is through thoughtful, respectful herding of their customers. Most of the community sees no problem in the current model discussed above. We simply despise the blatant violation of FDCA policy by headshops, and THAT is where the problem, if any, resides. It is still assumed that the 660 poison control center calls was a result of adulterated product from headshops, not reputable vendors online offering Mitragyna speciosa.

This proposed ruling was an extreme shock because we all have the most upstanding customers of any industry. Buyers of this material are the most knowledgeable minds out there. In this Mitragyna community, there is such a bond, because we all truly care about each other. It feels as if government is simply trying to intervene because of corruption. What else would be the reason? It can’t be that the ones behind this action are simply unknowledgeable. Don’t we all have the same Internet to compare notes and collectively research together? This is a new Era of knowledge! There is no longer an excuse for not having the answers or facts. Never again can the wool be pulled over one’s eyes. The laws and policies which govern our people are outdated and need to include public opinion and science.

“In an attempt to find out about these blocking capabilities Varadi injected mice with mitragynine pseudoindoxyl twice a day for a month. Then he checked if they could feel pain, using techniques such as putting them on a hot plate. In such experiments morphine usually loses its painkilling effects after five days. But after 30 days on a consistent dose of mitragynine pseudoindoxyl, the mice still showed numbness to pain. “It was the most exciting experiment I’ve ever done,” Varadi says. In other experiments Varadi and Majumdar reported that the mice exhibited few withdrawal symptoms from mitragynine pseudoindoxyl—and they displayed no indication that they actually enjoyed taking the drug. “[This is] early promise it’s nonaddictive,” Majumdar says. His team reported its findings in The Journal of Medicinal Chemistry LAST MONTH. <——– !!!!!!
Varadi says his results indicate that mitragynine pseudoindoxyl may have the peculiar ability to both activate the mu receptor—possibly making it a powerful painkiller that also reduces addictive and potentially deadly side effects—as well as lower withdrawal and tolerance. “It’s a double whammy,” Varadi says."

….
The Journal of Medical Chemistry entey referenced within that article has a publish date of 8/24/16, which is ONE WEEK before the DEA published their "Notice of intent" to ban the two main compounds found in the plant. We find the timing of the proposed ruling to be very interesting. Here, scientists just gave us confirmation of how unique the action of the compounds are, and how safe and effective it is, and the DEA is hastily going to say otherwise? The research on lab mice (and rats in other research) evidence strong conclusions about of the following benefits: low withdrawal symptom potential, no tolerance issues, nonaddicting, low toxicity, yet it has amazing pain-killing properties! This is promising and most exciting research that finalizes 100% success in the lab. The next tests would be humans right? But do we really need it? We already have millions of Americans vouching for its medical acceptance, not to mention many other tens of millions using the plant indigenously long before an FDA or HHS ever existed).

With the swiftly premature decision by the DEA to propose a "rule" whIle completely ignoring science (and that one established scientist stated it was the most exciting experiment he's done), this arouses great suspicion, especially when it was obviously thrown together only one week after this Journal entry was published. When we need to investigate actions like that, it is really difficult to willingly welcome more regulation, especially by the FDA. Why would we try to move backwards by marketing/selling "kratom" as a dietary supplement when another Agency is trying to forcibly push the tree into the FDA and HHS jurisdiction? That's essentially their end goal. The American people do not want corrupt agencies controlling our lives.

There needs to be more pressure on HHS to acknowledge Mitragyna having accepted medical use based on studies like these. Until Karen DeSalvo or others calling the real shots will act upon science and the demands of the People, then the DEA will continue to distract and waste our tax revenue. Go after the drug pushers.. headshops and doctors.

We appreciate this informative response. The problem is that the kratom industry, as in all industries, have some vendors who do not comply with the practices outlined above. The actions based upon this small minority contributed to a proposed ban of kratom.

CRE believes that at this late date in the regulatory process actions have to be taken to curtail the ban.

We would appreciate your views on this proposed statement by CRE assuming that DEA does not issue a final order,

Draft CRE Statement for Comment

DEA Has Acted Responsibly on Kratom: The Kratom Community Should Reciprocate

Several weeks ago the Drug Enforcement Administration (DEA) moved to institute a ban on kratom. Kratom is a herbal product that has been in use for decades, if not centuries. It is sold legally in both Canada and Mexico. As a result of a considerable outpouring of support for kratom by the American public the DEA continues to review its strategy for dealing with kraton prior to instituting a ban.

Concurrent with the DEA review the kratom community should initiate a forward looking strategy which will address the issues under review by the DEA. More specifically, the kratom community should present a Petition for Rulemaking to the FDA which would request that kratom be regulated as a dietary supplement. The resultant regulation would be subject to notice and comment and would address a range of topics, including dosage, adulteration, health claims, misuse, labeling and misbranding.

The Petition for Rulemaking should also request that related rulemakings be initiated concurrently with the one directed towards regulating kratom as regulatory supplement, including the following directives which are to be inforce until which time the aforementioned rulemaking is completed:

l. Cease FDA inspections and seizure of product based upon the conclusion that kratom is a NDI, new dietary ingredient.

2. Terminate seizure of product by customs officials.

3. Issue a directional notice to the financial industry to process billings related to the shipment of kratom.

The FDA has decades of experience in the regulation of dietary supplements. The FDA has the resources and technical capability to address issues raised by the DEA with respect to kratom. Consequently the initiation of a rulemaking will provide an analytical forum for addressing topics of concern; a forum where sound science will be the prevailing metric.

CRE has an Interactive Public Docket titled The Kratom Policy Forum at http://www.thecre.com/forum11/; members of the public are encouraged to express their views on the regulation of kratom as a dietary supplement.

Thank you again CRE. While regulation is certainly preferable to prohibition, the FDA is corrupt. They are the ones that duped the DEA into this emergency scheduling. One need not look further than the import alert that at the very least is deceitful and the worst corruption as to the alleged dangers of kratom. Kratom does not cause seizures or any of the other alleged dangers listed in the alert.
I agree the kratom community has done an amazing job in self policing vendors and having a rigorous process to become a vetted vendor. Ideally this would be available to the public at large to protect them as well.
I think we need to take a good look at the FDA and clean house so that it becomes a useful and productive regulatory agency instead of being the lap dogs of big pharma. Additionally they need to be open minded about natural products such as kratom instead of insisting everything must be manufactured and put in a pill.

Look at the FDA’s horrible and ignorant stance, clearly unwarranted, full of inaccuracies and fearmongering when considering federally-funded reesearch:

“Furthermore, based on FDA’s review of the publicly available information regarding kratom, there does not appear to be a history of use or other evidence of safety establishing that kratom will reasonably be expected to be safe as a dietary ingredient. In fact, the scientific literature disclosed serious concerns regarding the toxicity of kratom in multiple organ systems. Consumption of kratom can lead to a number of health impacts, including respiratory depression, nervousness, agitation, aggression, sleeplessness, hallucinations, delusions, tremors, loss of libido, constipation, skin hyperpigmentation, nausea, vomiting, and severe withdrawal signs and symptoms. In the absence of a history of use or other evidence of safety establishing that kratom will reasonably be expected to be safe as a dietary ingredient, kratom and kratom-containing dietary supplements and bulk dietary ingredients are adulterated under section 402(f)(1)(B) of the Act [21 U.S.C. 342(f)(1)(B)], because they contain a new dietary ingredient for which there is inadequate information to provide reasonable assurance that such ingredient does not present a significant or unreasonable risk of illness or injury.”

This action to ban kratom clearly does not appear to be coming from the DEA. But it is not the FDA either, because they would have mentioned actual research that would contradict their stance. The stance does not fit the science. The source of the push to ban kratom is coming from someone other than a government entity. The government departments all make this quite revealing when considering the research already done.

The DEA gets told what to do by the FDA and NIDA which are divisions of HHS.
Absolute power corrupts absolutely-Henry Kissinger

Anonymous

September 28, 2016 at 11:45 am

Regulation of this product as a dietary supplement is a much more appropriate measure than an unsubstantiated ban based on the long quiet history of this plant. As suggested by the CRE, please consider this approach rather than moving it directly to Schedule 1.

This is exactly what we have been wanting all along. Our community has been dying to have regulations over how this is marketed, quality control, claims, and dosage but the legal harassment by the FDA has made this entirely impossible! We are all in a position to cede to some regulations we just need the FDA to recognize that Kratom is an important dietary supplement to all of us who use it for whatever ailments.

I think that given the current situation, regulation is the best option. My only concern is that kratom will become prohibitively expensive, keeping it out of price range of many uninsured, disabled Americans who use it now. If the cost could be kept as low or close to as low as it is now. I am all for regulation. If regulation will preserve our access to this herb then that is what should be done. It’s certainly better than scheduling it.

Thank you CRE for staying with this issue. Regulation is preferable to prohibition. But I agree with those who express concern that kratom will become expensive. I discovered kratom at my lowest low. Fortunately what little money I had covered my first kratom purchase. I hate to think what would have happened if I had not been able to afford that first purchase. I have an amazing life today. Kratom does what nothing else can, it turns off all the cravings my body and brain push on me. But it does so much more. Kratom works with my doctor-prescribed medication and my paralyzing anxiety and depression are gone. I can leave the house. I can go to work and my children have their mother back. I feel normal again. If regulation is the way I get to keep my kratom supplement (without going broke), I’m all for regulation.

What would be wrong with treating Kratom like coffee ?? There are so many different kinds and locations it comes from. It is about as harmful as coffee or maybe even less harmful, because it works for a myriad of health problems. I just want to be able to afford it. A lot of us older people on a fixed income. I cant function without Kratom because of cronic pain. I cant go back to laying on the heating pad all the time. I dont want big business to corner the market and control the price. God help us.

I think the best option would be to regulate Kratom, like all herbal products and put in health food stores. It has been so demonized it would need some better PR than it has been getting to go mainstream. It would be hard to establish dosage as it is all different and people are different. It is such a complex little plant as are all the things God made.

One supplement I’ve never been able to understand is yohimbine HCL (an extract purchased from almost everywhere for cheap) which has a 2.5mg effective “dose”. It is very variable – some people like me can’t handle 1mg, and others say 25mg doesn’t affect them. For myself, 1mg causes hypertension with feelings of extreme impending doom as if I am about to die. My heartrate goes way up too. A 10g can of this stuff is scary inexpensive, and if a toddler got ahold of it and dabbed his finger on the substance, it could cause death.

If there are already so many supplements with extreme variations in dosage amount and effect, why not work on those substances where the threat to public health is actually there? Really, what’s the yearly Poison Control call tally for yohimbine HCL or yohimbi bark? I bet it is higher than kratom.

2.5mg is tough to measure properly. Most consumer scales for supplements are precise to 10mg increments. That means HOPEFULLY the scale being used is accurate for weighing a 10mg pile of yohimbine HCL, and visually separating it into four equal piles. Look up “yohimbine HCL overdose” on Google. I am convinced the CDC data for kratom is not truthful.

My point is that just because it is regulated and put into a health food store or the supplement isles of grocery stores does not at all guarantee safety for the public. Somehow, some substances gain acceptance into the supplement market, yet a plant faces so much scrutiny for having “variable dosage” information. Everyone is already so different, and at least nature is more consistent than the so-called “certified via lab” supplements on the market. We’ve all experienced drastic variations in the overall quality of so many supplements coming from labs, that we tend to trust nature more than humans at this time.

I actually realized most scales are only precise to 100mg! That means someone would have to split a 100mg (tenth of a gram) pile of yohimbine HCL into FIFTY piles to arrive at 2.5mg doses. With kratom, people don’t have to worry so much about overdosing like this.

Susan Ash
Ok, here is the deal with AKA legal strategy. The DEA has made it pretty clear that no action will be taken Sept 30 and that should any action be taken they will give people (like the Congressional letter signees for example) at least 48 hours notice. We don’t know when, or even if, it’s going to happen but we can say with near certainty it won’t be Friday.
A Temporary Restraining Order (TRO) or petition for injunction is to be filed AFTER the DEA acts, not before, since there is no action yet to enjoin. We do not support filing litigation precipitously and are working hard to present our evidence and arguments to DEA, we expect DEA to take our arguments very seriously and to meet with our attorneys, as well as take those comments from the many members of the public who have voiced their opinion and shared their stories, and from the many members of Congress who are supporting their constituents very seriously. People filing a lot of injunctions on their own claiming harm are making medical claims which could hamper our efforts that this should be treated as a botanical supplement and not a drug. And a judge will tell them that even with a schedule 1 substance, a doctor can still prescribe (I know this is a lot of BS to us, but that’s what a judge will say) so nothing but some large hoops to go through will actually cause harm. I am just reporting from consultants and attorneys, please don’t shoot the messenger.
The legal letter we submitted is far more detailed than what a TRO will entail. Our attorneys have always known we wanted a TRO and have been getting prepared for one. It will be a lot easier to put together now and a lot less complicated with the highly detailed letter they already submitted. What we are now doing is trying to determine the best angle we should take to base a TRO on, should the scheduling happen.

EDIT : Clarification from Susan Ash : “ALERT! There is quite a bit of confusion over my last post and I don’t have time to go through and answer all the questions. I stated that we are confident that the ban will not go into effect on Sept 30. I NEVER said we won or that this is over; only that the DEA still needs time to respond to congress, our attorneys, the public, etc. and that we expect them to take us very seriously. ENDLESS PRESSURE. ENDLESSLY APPLIED.”

Regulation as a dietary supplement or health supplement is what should be done how could Canada get it so right by classifying it as a health supplement but yet we want to schedule it under schedule one it seems so insane to me. The FDA the DEA and Pharma need to keep their noses out of places they don’t belong. When the Mitragynine alkaloid was studied it produced all of the benefits of a prescription painkiller without any of the side effects no loss of cognitive function no respiratory depression, little to no affinity for addiction. I’ve seen articles from scientists saying they’ve never seen anything like it before, so of course they wanna ban it to protect big Pharma profits. This plant is literally the answer to the opioid epidemic

Kratom should be considered a dietary supplement as it is with Kava. We should be careful not to make any medical claims about it but with this firestorm we have had to.go through, maybe it saved it. We should all be PUSHING FOR IT TO BE A DIETARY SUPPLEMENT and we can keep it like it is. Research Kava and see what I mean. Kava worked like a valium for me. Dont need it very often but better than pharmaceuticals.

I agree with CRE that this extreme measure by the DEA was spurred, at least in part, by unscrupulous vendors and gas stations marketing kratom as “herbal heroin” and other such nonsense. The packaging on some of this kratom is cartoonish, reminiscent of the “Joe Camel” days when cigarette companies were accused of marketing to children.

This needs to stop. Not because kratom is dangerous, but because it is mild and helpful, and does not get you “high.” Silly marketing tactics about “legal highs” are misleading and unethical, and have stained the reputation of a plant that, used responsibly, helps hundreds of thousands of adults live better lives.

It is an herbal supplement, and in its whole-leaf form has more than 20 alkaloids that interact in a spectrum that chemical synthesis in a lab will never replicate. The plant is valuable as a supplement, and we must keep it safe for those who choose to use it. These people are not experiencing adverse effects. Quite the opposite. They should not have their quality of life taken from them through a sensless ban on an herb. But, they also should have assurance that what they are buying is unadulterated and safe. There are many, many quality vendors who practice safe methods of handling and packaging kratom. They should be brought forth and consulted on their methods, and helped to continue their businesses.

A ban — or any scheduling of kratom — is not the answer; it will only send the ethical vendors out of business and allow unethical vendors to thrive on a black market. At that point, we truly do have a “Wild West” kratom market, and people will suffer in countless ways.

Thanks CRE! I agree with regulation of kratom. Also wondering about the ban and the economic repurcussions on the kratom farmers. Back when kava was banned, the kava farmers were eventually able to fight to get the ban lifted through legal action against the wto because the kava was shown to be safe when the correct parts of the plant were used. So a hasty ban based on flimsy information was eventually overturned, sound familiar?

CRE, thank you for putting forward a sensible plan that addresses both the DEA’s stated health concerns and the public outcry from those who benefit from kratom, not to mention the scientific community’s plea to research its health benefits. I love going to my local herbal shop which sells teas and supplements of all kinds to purchase kratom for relief from chronic pain due to a spinal condition.

I did not even know prior to the DEA’s announcement that kratom was sold in head shops and gas stations. This likely contributed to false impressions of this herbal remedy. Regulation is a logical middle ground that could ensure that labeling states warnings of overconsumption and recommended intake. This would help prevent the calls to poison control centers the DEA references because people would be educated about the nausea that can occur if one consumes too much and not panic.

I have been scared and losing sleep about the nearing date of the proposed ban and still in disbelief that I could be considered a felon for safely caring for my pain in a way that allows a full and active life without the impairment of prescription drugs. Having the CRE, scientific community, credible media sources, 51 House Reps, and now Senator Orrin Hatch standing up for the rights of the kratom community and in turn all Americans, has been truly a gift. Thank you.

I am a firm believer in the power of well-placed regulation – for instance I want to know that the Vitamin C I am taking does not have strychnine in it for “added kick.” I have been using kratom off and on for several years, and I only use regular leaf kratom. In the past few years I have noticed an uptick in the availability of “high potency kratom (HPK)”. This has been of concern to me, as I felt that the increased supply of HPK would lead to potential adulterations of the kratom, which in turn would no doubt lead to poison control calls and eventual DEA regulation. I have read in various forums that unscrupulous suppliers had added opioid substances to their kratom – which is unconscionable and illegal (as once opioids are included in the HPK mixture, the vendor is officially trafficking narcotics). I, and the vast majority of kratom users, DO NOT WANT opioids added to our kratom. I suspect that we would welcome regulation and testing of the kratom to assure that it is not laced with unwanted substances… and this is true for everything I consume, from Gingko Biloba to Vitamin C (i.e. 90% of US consumed vitamin C is made in China and should be tested). So issue one – regulate and test for adulterated product, and prosecute anyone that violates current Federal Drug Laws to the maximum extent of the law.

Secondly, as a responsible consumer of kratom, I find that it is fairly pricey to use on a regular basis – in excess of $500, possibly in excess of $1000 annually, if one is to drink two cups of standard grade regular kratom leaf tea per day. Thus, I do not see many “kids” getting heavily into the use of a fairly expensive tea leaf that produces little more effect than a strong cup of tea. In fact, the first time I used kratom I was quite young, and looking for a cannabis type effect. I brewed the tea and was completely unsatisfied – it was too expensive and didn’t do anything noteworthy. I ordered it only once, and did not re-order until years later when I was better educated on what kratom should be used for. So, in my opinion, kratom is clearly not going to be a choice for ‘kids’ with limited budgets. I would think most of these ‘kids’ whom we all want to protect, will far prefer the high from cannabis – as when I was younger, that was certainly my preference. Of course, now that I am older, and responsible, and have to work for a living, I prefer kratom and would not even put cannabis in the same category. Kratom is a plant, used by older, responsible people. Again, in my opinion, the only potential danger to the youths of this country would be from the adulterated HPK. They will not get “high” from standard kratom leaf tea.

In conclusion, I favor a modest form of regulation on kratom, and I have long since been put off by the disclaimer on all the kratom websites that the product “is not intended for human consumption.” We all need a coming-to-Jesus moment about this plant. Millions of Americans consume kratom every day. Many vendors are selling a tea product and most people are responsibly consuming this tea product. These responsible users are drinking kratom tea to help with a myriad of health and psychological issues – from weaning off opioid addictions & alcoholism, to fighting chronic pain, fatigue, sleeplessness, to fighting anxiety disorders. It is my understanding that kratom is also very high in antioxidants, and I expect that it has all the health benefits of green tea. Kratom should be available along side of other plant based supplements, like Kava Kava, and it should not have to be sold under false pretense. It is a bourgeoning industry, and its potential for helping far outweighs its potential for harm – especially when the nefarious vendors of this plant are removed from the market.

Finally, being a Floridian, we have lost a large segment of the citrus revenue to a citrus virus over the past decade. Florida, and the southeast US may provide a great growing climate for kratom farms, and their is high potential for large profits for farmers that may want to get involved in the domestic production of a regulated kratom product. Kratom has gone from being unknown by more than 99% of Americans, to being a large and rapidly growing industry over the span of a few years (this is the basis of the DEA’s action, is it not?). In a sluggish economy, kratom farming could be the next green revolution – the first of which has made many people in Colorado, Washington, Oregon, and soon several other states – very rich. And this is fitting for America – because since day one, we have been making money on our plants. Only now, instead of cotton, sugar, and tobacco, its cannabis, hemp, and soon, could be kratom. Certainly, these newer profitable plants require less work and pack a much higher profit margin.

Only… kratom trees are not going to be a good cash crop here in the states because it is picky about the conditions needed for even a low yield. Consider that the tree leaves being picked in Indonesia are almost 100ft tall.

One thing that has been easy for supplement industry to get away with is their addition of chemicals into product. I have not seen any adulteration on imports of Mitragyna at all, and if any product is getting adulterated, it is happening on the local end (somewhere after the import lands). Since most customers are older adults (many senior citizens and vets) desiring natural leaf, there is very little incentive for an online vendor to spend extra resources mixing in something to an already perfect and desired product. Customers would also know about it, and people would fail UA’s all the time. In my ~10 years experience with this tree, I have never heard of anyone failing a UA for natural green leaf kratom.

Although I am speaking personally, and not on behalf of the kratom community, I am getting the sense that sensible regulation as a dietary supplement is the ultimate goal of the vast majority of kratom consumers. Being very active in the coordinated reaction to the DEA’s letter of intent and having engaged in much dialogue with others who are also highly invested in the issue, not only do I get the sense that this would be an acceptable (even preferential) outcome for all parties involved; I, for one, would welcome regulatory standards for the safety and responsible marketing of kratom. We do not need the government to protect us from ourselves, responsible kratom users and vendors have been self regulating and policing the market for years, but we could use, and would be grateful for, assistance ridding that marketplace of the shady, unethical elements, and potentially impure or adulterated products that have become a stain on the good name of kratom. I do not wish to speculate here as to the motives of the DEA or other entities in this matter, but if indeed the DEA wishes to act in the “public interest” I think this (regulation as a dietary supplement) would be a mutually agreeable outcome.

I agree that regulation as a dietary supplement was the outcome that HHS and FDA have been wanting all along, but it is still interesting that in a “Wild West” industry like this, there still is very little evidence of concerning public harm potential compared to the dietary supplement industry itself! For some reason, there have not been an alarming amount of issues for the decades this plant has been available here for purchase. It’s almost as if this market has been self-regulated by the consumers. This relationship with consumers and their vendors is one of loyalty and trust, just like with anything else. The experience between a consumer and the larger companies selling dietary supplements through large distribution such as grocery stores and headshops evidences a very different experience. feel that we will actually see problems after the industry is regulated. That’s just how it works. I am all for a division which oversees the kratom industry directly, and any reputable vendor right now would absolutely pay the “fee to do business” because it would boost sales. People are losing trust in larger companies which cut corners and deliver subpar product once they “go big”. I can’t tell you how many times I found something seriously wrong with a big brand name food item from the store. Whether it was moldy growth in a bag of shredded cheese or an olive pit on a frozen pizza to break my tooth and cause large dental bills, we could all agree that regulation does not insure saftey. For whatever reason, a box of baking soda full of fagrance and other chemicals at the store is allowable, and even restaurants passing inspections can douse their customers’ food with fragrances from dispensers above (or the restroom, same air space), but nobody sees a problem with that! How are carcinogens allowed in consumer products, with no company being slapped on the wrist for it?

Let me leave everyone with this… if a kratom customer found a hair in their bag, you can bet the whole community would yell about it. However, that vendor would likely never allow a hair to get in product ever again. There are repercussions for bad behavior or QC in the current model already, and reputations are important to uphold. We can’t say that for big, regulated business. It’s just a fact. The truth is that regulated businesses are allowed to make big mistakes and not go down for it. The reason is because they PAY to PLAY.

We have to consider what pushing an industry with an already amazing track record is going to do. I am very worried about this. We need to look at history and understand that this move to regulate is not about safety whatsoever.

Before today, I had not shared this with anyone not in my immediate circle. It is not something I like to talk about, but I feel like it is important. Especially given what the DEA is trying to do with the product, Kratom right now. I am a 36 year old female with a 20 year old son. I have worked as Provider Credentialing Specialist for over a decade.

First, there are few things about me you need to know.
In 2003 I had breast reduction surgery that was botched. It caused tissue and nerve death in both breasts. And that dead tissue became calcified inside my body. The result was a constant feeling of white hot, searing pain in both breasts that was exacerbated by any extreme temperature. If it was too hot our or too cold, I could not get out of bed. I would hug a heating pad to my chest, while lying in bed sobbing. I lived this way for over a year.
In 2004, I was in a car wreck. The steering wheel locked down on my legs while the impact detached my seat from the frame and threw the rest of my body sideways while the steering wheel kept my lower body stationary – thus causing damage to my lower back and hips.

I was in chronic, debilitating pain. I could not function. It was hell.

Then I trusted the wrong doctor. He did make good on his promise to get me back to living my life again, but only with pharmacological aid in the form of Hydrocodone. It worked for awhile, but over time I built up a tolerance to it’s analgesic properties. After that I was put on Morphine Sulfate ER (extended release), and Oxycodone IR (instant release) for “break through pain.”

As time went on, I went back to work. I was able to live a fairly normal life. Then I made the mistake of not picking up my prescriptions one Saturday afternoon. My pharmacy closed at 2pm on Saturdays and was closed Sundays. I was out of my meds, but I figured I could just pick them up Monday. At this time, I had been on these medications for almost a year. By Saturday evenening I was violently ill. I was SICK. I was sneezing non-stop. I couldn’t keep anything on my stomach. I had cold chills, yet continued to sweat profusely. My legs kept kicking all on their own non-stop (this doesn’t sound so bad until you actually experience it, but the Restless Leg Syndrome was particularly hellish, as it kept me from being able to relax and seek oblivion in sleep). In addition to all of this, my entire body was screaming in pain. Not just my breasts, hips, and back. Even my skin hurt to be touched. Bathwater felt like bees stinging my entire body. I was a mess, and it wasn’t until the following Sunday night that I realized what was happening to me. I was experiencing opiate withdrawal. And my God, was I horrified. Not only that, I felt immense shame. I felt like I was a junkie. It really messed with my head. However the real damage done that weekend was the fear. Pain is a funny thing. The fear of it can be debilitating. For a long time I was more afraid of the pain from withdrawal than anything else in my life. It would take me almost NINE more years to overcome that fear, finally say ENOUGH, and choose to quit both pain medications cold turkey. Something I do not suggest any of you living with chemical dependency do. It is dangerous, and it really is something that needs to be monitored by a health care professional. However, I am telling MY story as it happened.

In 2014 I had lost my job, and just about everything else. I had resented the fact that my body could not function properly without this chemical for years, and on May 8, 2014 I was just mad enough that I said “to hell with it.” While I had no job to report to, I would get rid of my meds, and get off of them once and for all. I was terrified, and unsure if I was strong enough to endure the pain of withdrawal. However, my anger and spite have always been far stronger than my fears once they manifest, so I did it.

Within two weeks I actually found myself begging God to let me die. I am not proud of this, in fact it shames me. However, it is the truth.

That’s when I first discovered Kratom. It helped me sleep a little, eat a bit, relaxed my legs some, and enabled me to fight the pain radiating from my entire body while going through opiate withdrawal. My brother had neighbor that drank Kratom tea at the time for his own purposes. When Ben learned of my condition, he came over with two bottles of the concentrate and a bag of the tea. After confirming it was not physically addictive, and harmless if ingested properly, I decided to try it. It turned out to be my salvation. It allowed me to sleep about 4 hours a night (which is a ton when going through withdrawal). It calmed my legs, so I didn’t constantly feel the compulsion to move them. I can’t express how awful that is, btw. It doesn’t sound so bad until you’re exhausted and everything is screaming in pain. Yet you can’t rest at all because you can’t stop moving your legs. It’s like a a physical sneeze that won’t go away. But I’m getting off topic. Kratom took just enough of an edge off the worst symptoms, that I could endure another day until enough time passed, and I started to slowly feel more normal again.

Although my new “normal” kinda sucks, at least I am free. My lower back and hips still kill me all the time. I can’t take ibuprofen thanks to a peptic ulcer I developed. And this time of year is sheer hell thanks to the additional pain that comes with the changing temps and atmospheric pressure. Over the last 2 and 1/2 years, I have used a little Kratom from time to time to take the edge off the pain on those days it feels impossible to get out of bed.

There is a stigma attached to those who develop either an addiction or chemical dependency. And most people have no idea that there is a huge difference between addiction and chemical dependency. I’m lucky I only developed a physical chemical dependency and not an all out addiction to opiates. That’s why I was able to successfully stop taking them, and never once be tempted to take them again – even knowing they’d relieve my pain.

It has taken awhile, but I’ve realized I have nothing to be ashamed of. In fact, I’m rather proud of myself for choosing to live my life on my terms without pharmacological intervention. I still have a bit of kratom when it’s particularly hard to get out bed this time of year (and also in the spring for the same reasons). But for the most part I push through normal every day pains I feel.

I know many people who have it far worse than I do. Kratom has helped them immensely, and I would hate to see all of them suffer what is basically Big Phama Greed.

Bravo Nance for sharing your story! Thank you for your honesty, I’m sure it wasn’t easy. I pray that those who need to find kratom still have that option when they’re ready. Each of us is unique. Each and every experience makes us who we are today. I’m sorry you had to go (and still go) through so much pain. Your story has helped at least one person today, me. Thank you.

quite profound and thought-provoking and also very appreciated.
I also want to thank the CRE for their invaluable work, relentless pursuit of the truth, and insight with this Kratom issue.
If regulating Kratom as a dietary supplement will assist to stop or delay the scheduling of it then I am all for it. I don’t know enough about how that works but perhaps it is a give-and-take between the truth and the government. It worries me to Institute more government regulation on anything because whenever that happens there are always several intended consequences.
What I know about kratom has been learned from reputable vendors and my own personal experience. Allegations of death due to Kratom is shocking and to me unbelievable – now we have all learned that the stats sited by the DEA deaths have been associated with other drugs or chronic under-lying physical conditions. As I understand there was one incident where a man killed himself in Colorado somehow due to kratom. I would have to believe that there was some underlying mental issues but I do not know the story. While it is very sad and I have express sympathy for this man’s parents who have been reported to have blamed it all on Kratom, I find it hard to believe that it was not precipitated by other events

I apologize a portion of my comment was cut off. The following the rest of it:

My point in even mentioning these deaths is that while I don’t take them lightly they are few and far between compared to the many hundreds of thousands of pharmaceutical products that are ingested by our society and cause far more deaths. In other words, in my opinion, Kratom needs no government regulation at all.
With that said, I will stand on the side of regulation as a dietary supplement if that is what is necessary to appease our government mama who needs to take care of all of us – even those of us who have taken care of ourselves very well and responsibly.
Thank you for allowing us to express our comments and opinions.

It deserves restating that, considering the lack of regulation to this point, the kratom marketplace and product usage has a remarkable track record of safety. With due respect given to the lives of the deceased, 15 fatalities with tenuous connections to kratom use over a period of years is, rather that a warning sign, a testament to the safety of this leaf. Once again, I am fully in support of sensible regulation of kratom as a dietary supplement and a free and open marketplace where vendors and consumers may continue to thrive.

It seems today, 10/1/2016, that the DEA has corrected itself and is allowing the enforcement of the “ban” to be considered as part of a two year study period or trial. Permanent enforcement may not begin before those years are completed including with public opinion, which has been ongoing for some time. The DEA must respond publicly as to this “trial” as it appears they have not even consulted with the representatives of the country(public). I am monitoring this and have not heard of any arrests concerning kratom leaf. This is what I have witnessed today.

I agree that taking action to make kratom a dietary supplement is the way to go. I appreciate CRE for all your hard work and everything you’ve done to bring this subject into the light. It is of the utmost importance that this supplement remains accessible to all of the many, many people that benefit from it.

Thank you so much for all of your diligent work, information, and awareness; in reference to last year’s debacle/mishap by some of our nation’s governmental entities.

I’ve been compiling a list of over 200 research studies, journal articles, press releases, and ‘general facts’; over the course of the past year, and below is that Google Drive link. Please feel free to use/share/etc.: